Illinois Appellate Court
Civil Court
Workers’ Compensation Act
Circuit court properly imposed section 19(k) penalties and Section 16 attorney's fees against employer for its deliberate refusal to pay TTD solely based on employee having reported work accident 6 days after accident rather than on date of accident, although Worker's Compensation Act allows employees 45 days to report an accident. Employer's policy to not pay TTD benefits if accident is not reported on day it occurs is unreasonable, given Act's allowance of 45 days to report and also given that many injuries do not manifest themselves until later. (HOLDRIDGE, HOFFMAN, HUDSON, and HARRIS, concurring.)